Schachenmayr v. Commissioner

WOLFGANG AND MARTINE SCHACHENMAYR, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Schachenmayr v. Commissioner

Docket Nos. 4145-86, 4150-86, 4154-86, 4156-86

United States Tax Court

T.C. Memo 1991-281; 1991 Tax Ct. Memo LEXIS 323; 61 T.C.M. (CCH) 2963; T.C.M. (RIA) 91281;

June 20, 1991, Filed

Decisions will be entered under Rule 155.

William J. Dreyer, for the petitioners.

Christopher B. Sterner, for the respondent.

WELLS, Judge.

WELLS

MEMORANDUM FINDINGS OF FACT AND OPINION

Respondent determined deficiencies in and additions to tax as follows:

Additions to Tax Under

Taxable

Sections 2